WGS Solicitors caught allowing £15m in art & cash through client account

Tribunal fines WGS Solicitors £25,258 for allowing client account misuse and AML failures.

The Solicitors Disciplinary Tribunal has fined WGS Solicitors £25,258 after a string of serious regulatory breaches, including allowing its client account to be used as a private banking facility for high-value art transactions and failing in its anti-money laundering (AML) obligations.

The Tribunal ruled that the firm, based in the UK and authorised to provide a full range of legal services, breached several principles of the Solicitors Regulation Authority (SRA) Rules, including both the 2011 and 2019 frameworks. The misconduct spanned from June 2017 to March 2021 and involved the handling of millions in client funds without adequate oversight or compliance.

Central to the scandal was the firm’s involvement with two high-net-worth clients, referred to in the judgment as Person A1 and Person B1. Between May 2018 and August 2020, the firm helped Person A1 channel over £15 million worth of US dollar and euro transactions through its client account. These funds were used to purchase artwork via a Seychelles-based special purpose vehicle (SPV), with emails from Person A1’s assistant explicitly requesting confidentiality to avoid banking scrutiny.

Despite early reservations, a senior partner at WGS agreed to facilitate the payments. Records show large amounts entering and leaving the client account, including a $1 million transfer to a prestigious art gallery on 22 May 2018. Over time, the firm processed a series of similar payments without ensuring appropriate AML checks were completed or documenting proper transaction justifications.

Meanwhile, the second client, Person B1, used WGS’s services for property-related transactions but also made 113 separate cash deposits totalling nearly £1.5 million into a general client ledger. These payments, described as “remittances” in the bank records, were later revealed to be made in cash, raising serious red flags. Person B1 even requested that funds be pooled into a single general ledger for convenience, a move that contradicts established financial practice standards.

The SRA launched a forensic investigation in 2022 following three separate internal reports submitted by WGS itself. These reports flagged multiple breaches of the 2017 Money Laundering Regulations (MLRs) and the SRA Accounts Rules 2019. Investigators found that the firm had failed to apply customer due diligence (CDD), enhanced due diligence (EDD), and ongoing monitoring for both clients.

The Tribunal concluded that the firm had no proper procedures in place to comply with regulatory requirements. It determined that the breaches were within the firm’s direct control and spanned a significant period. It emphasised that WGS’s client account had been allowed to function as a private bank account, particularly in the context of the art transactions.

Despite the severity of the findings, the case was resolved by an agreed outcome. The Tribunal accepted the proposed penalty as falling within Indicative Fine Band Level 4 and found the sum of £25,258 to be “reasonable and proportionate,” based on the firm’s turnover.

In addition to the fine, WGS Solicitors was also ordered to pay £18,000 in costs.

While the individual roles of the two partners involved—Jonathan Richard Maurice Gerber and Bridget Catherine Miller—were mentioned in the wider Tribunal hearing, this particular judgment and fine were specifically directed at the firm itself.

The ruling has sent a clear message across the legal profession: misuse of the client account and AML lapses, especially when involving large international sums, will not be tolerated.